On January 15, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Baxter, Nancy,
and
Citizens Property Insurance Corporation,
for Insurance Claim
in the District Court of Collier County.
Preview
Filing # 126098835 E-Filed 05/04/2021 10:06:00 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA CIVIL ACTION
Nancy Baxter Case No. 11-2021-CA-000133-0001-XX
Case Type: CIVIL
Vv.
Citizens Property Insurance Corporation
anon |
AGREED CASE MANAGEMENT PLAN AND ORDER
The parties hereby submit the following Agreed Case Management Plan to the Court for approval:
Case Track Assignment! (check one — must be completed for cases filed 1/1/10 or thereafter):
(1 Expedited Track (Case resolved within 12 months);
(It is recommended that discovery and an alternative dispute resolution be completed
within 270 days after the complaint is filed and a final disposition entered within 365
days after the complaint is filed)
Standard Track (Case is resolved within 18 months);
{it is recommended that discovery and an alternative dispute resolution be completed
within 450 days after the complaint is filed and a final disposition entered within 540
days after the complaint is liled)
O = Complex Track (Case resolved within 2 years)
(Case will likely be declared complex per Florida Rule of Civil Procedure 1.201)
Case Deadlines and Events
DEADLINE OR EVENT. AGREED DATE
Statement of Facts and/or Counterclaim(s) Plaintiftts)} 03/15/2022
Defendant(s): 03/15/2022
Identification of facts the parties believe to be disputed oo.
Plaintiff(s): 03/15/2022
Defendant(s); 03/15/2022
Identification of the issues of law to be decided by Plaintifits)| 03/15/2022
the Court
Defendant(s); 03/15/2022
Motions to Add Parties or to Amend Pleadings Plaintiff(s); 03/15/2022
Defendant(s); 03/15/2022
Disclosure of Fact Witnesses
Plaintiff(s): 04/15/2022
+ Case disposition times for all Case Tracks have been established in accordance with Florida Rule of Judicial Administration
2.250(a)(1)(B). Although Standard and Complex Track cases may or may not be resolved with a jury trial, it is expected that
Expedited Track cases will be resolved without a jury trial.
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 05/04/2021 10:06:00 AM| . Defendant(s): 04/15/2022 |
AGREED DATE
05/15/2022
DEADLINE OR EVENT.
Disclosure of Expert Witnesses Plaintifi(s)}
Defendant(s); 05/15/2022
Filing of Exhibit List
05/15/2022
Plaintiff(s):
05/15/2022
Defendant(s);
Discovery Deadline for Fact Witnesses
Plaintiff(s): 05/15/2022
(All discovery must be commenced in time to
be completed before this date) Defendant(s):
05/15/2022
Expert Opinion Available to Opposin: Party woe
Penwe Pposiné Plaintiff(s): 05/15/2022
{It is recommended that the last exchange occur 4 months
before trial and 1 — 2 months before discovery deadline to
allow time for expert depositions. This does not require a Defendant(s):
written report unless otherwise required by the rule.)
05/15/2022
Discovery Deadline for Expert Witnesses 06/15/2022
Plaintiff(s);
06/15/2022
Defendant(s);
Completion of Alternative Dispute Resolution (ADR)
Deadline: —06AS2022 b
(Mediation is mandatory unless the parties agree to another FO des fuel
form of ADR. If early ADR is selected and it does not result
in settlement or disposition of this entire action, a case fv GA
management conference will be scheduled within 45 days Type of ADR: Mediation
from the date of ADR )
Deadline for Filing Dispositive Motions
(Court requires filing not later than 10 days prior to 05/15/2022
the pretrial management conference)
DD
Ske /ZA— 7 Gy
An Order wilJWe issued
by the Couft scheduling
the Pretrial Conference.
Pretrial Management Conference Date
(Unless early ADR is selected, a pretrial conforence date
will be scheduled within 45 days of the date of ADR not
resulting in settlement or disposition of this entire action.)
Other Deadlines or Events clit Fos A “7
Vie [pa- Gay)Trial Information
Estimated Date the Case Will Be Prepared To Go To Trial
(If counsel and unrepresented parties do not agree on the estimated date
on which the case will be prepared to go to trial, the Court may on its
own motion set the case for trial)
Estimated Length of Trial (specify the number of tial days):
Identification of Jury or Non-Jury Trial ~~
Delineation shall constitute a waiver pursuant to FRCP 1.430
The above-referenced schedule of deadlines will be strictly adhered to by the parties unless a change is otherwise agreed
to by the parties and approved by the Court. The Cowt will consider a request to approve changes to these deadlines
upon a showing of good cause by either party based on matters arising from an emergency nature or unavailability.
However, once the Agreed Case Management Plan has been approved by the Court, procrastination in completing
discovery or the unavailability of counsel will not constitute good cause for a change to these deadlines. The failure to
abide by these deadlines may result in sanctions by the Court, including the award of attorney’s fees, the striking of
pleadings, and/or a dismissal of the action.
Date:04/29/2021
Signature, address and telephone number of C ‘ounsel and Unrepresented Parties. Counsel must state FL Bar
number:
/s/ Daniel A. Alvarez, isi ake A, Roth
Daniel A. Alvarez Jake A. Roth
7750 SW 117th Avenue, Suite 206 600 North Pine Island Road, Suite 500
Miami, FL 33183 Plantation, FL 33324
dalvarez@alvarez.legal jake.roth@csklegal.com
Florida Bar No, 58842 Florida Bar No. 1025881ORDER APPROVING AGREED CASE MANAGEMENT PLAN
THE COURT having reviewed the preceding Agreed Case Management Plan and finding it to be satisfactory, it is
ORDERED AND ADJUDGED that the Agreed Case management Plan is hereby APPROVED AND ALL PARTIES
SHALL ABIDE BY THE TERMS HEREIN.
DONE AND ORDERED in Collier County, Florida on 5 “. | aH
i nm. Ps Brodie.
CERTIFICATE OF SERVICE
Pursuant to Rule 1.080 of the Florida Rules of Civil Procedure, conformed copies have been mailed
this 3 day of. Many , 2021, to the following:
Copies +o Cooneel of Record
Case Filing Date
January 15, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 126098835 E-Filed 05/04/2021 10:06:00 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION Nancy Baxter Case No. 11-2021-CA-000133-0001-XX Case Type: CIVIL Vv. Citizens Property Insurance Corporation anon | AGREED CASE MANAGEMENT PLAN AND ORDER The parties hereby submit the following Agreed Case Management Plan to the Court for approval: Case Track Assignment! (check one — must be completed for cases filed 1/1/10 or thereafter): (1 Expedited Track (Case resolved within 12 months); (It is recommended that discovery and an alternative dispute resolution be completed within 270 days after the complaint is filed and a final disposition entered within 365 days after the complaint is filed) Standard Track (Case is resolved within 18 months); {it is recommended that discovery and an alternative dispute resolution be completed within 450 days after the complaint is filed and a final disposition entered within 540 days after the complaint is liled) O = Complex Track (Case resolved within 2 years) (Case will likely be declared complex per Florida Rule of Civil Procedure 1.201) Case Deadlines and Events DEADLINE OR EVENT. AGREED DATE Statement of Facts and/or Counterclaim(s) Plaintiftts)} 03/15/2022 Defendant(s): 03/15/2022 Identification of facts the parties believe to be disputed oo. Plaintiff(s): 03/15/2022 Defendant(s); 03/15/2022 Identification of the issues of law to be decided by Plaintifits)| 03/15/2022 the Court Defendant(s); 03/15/2022 Motions to Add Parties or to Amend Pleadings Plaintiff(s); 03/15/2022 Defendant(s); 03/15/2022 Disclosure of Fact Witnesses Plaintiff(s): 04/15/2022 + Case disposition times for all Case Tracks have been established in accordance with Florida Rule of Judicial Administration 2.250(a)(1)(B). Although Standard and Complex Track cases may or may not be resolved with a jury trial, it is expected that Expedited Track cases will be resolved without a jury trial. FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 05/04/2021 10:06:00 AM| . Defendant(s): 04/15/2022 | AGREED DATE 05/15/2022 DEADLINE OR EVENT. Disclosure of Expert Witnesses Plaintifi(s)} Defendant(s); 05/15/2022 Filing of Exhibit List 05/15/2022 Plaintiff(s): 05/15/2022 Defendant(s); Discovery Deadline for Fact Witnesses Plaintiff(s): 05/15/2022 (All discovery must be commenced in time to be completed before this date) Defendant(s): 05/15/2022 Expert Opinion Available to Opposin: Party woe Penwe Pposiné Plaintiff(s): 05/15/2022 {It is recommended that the last exchange occur 4 months before trial and 1 — 2 months before discovery deadline to allow time for expert depositions. This does not require a Defendant(s): written report unless otherwise required by the rule.) 05/15/2022 Discovery Deadline for Expert Witnesses 06/15/2022 Plaintiff(s); 06/15/2022 Defendant(s); Completion of Alternative Dispute Resolution (ADR) Deadline: —06AS2022 b (Mediation is mandatory unless the parties agree to another FO des fuel form of ADR. If early ADR is selected and it does not result in settlement or disposition of this entire action, a case fv GA management conference will be scheduled within 45 days Type of ADR: Mediation from the date of ADR ) Deadline for Filing Dispositive Motions (Court requires filing not later than 10 days prior to 05/15/2022 the pretrial management conference) DD Ske /ZA— 7 Gy An Order wilJWe issued by the Couft scheduling the Pretrial Conference. Pretrial Management Conference Date (Unless early ADR is selected, a pretrial conforence date will be scheduled within 45 days of the date of ADR not resulting in settlement or disposition of this entire action.) Other Deadlines or Events clit Fos A “7 Vie [pa- Gay)Trial Information Estimated Date the Case Will Be Prepared To Go To Trial (If counsel and unrepresented parties do not agree on the estimated date on which the case will be prepared to go to trial, the Court may on its own motion set the case for trial) Estimated Length of Trial (specify the number of tial days): Identification of Jury or Non-Jury Trial ~~ Delineation shall constitute a waiver pursuant to FRCP 1.430 The above-referenced schedule of deadlines will be strictly adhered to by the parties unless a change is otherwise agreed to by the parties and approved by the Court. The Cowt will consider a request to approve changes to these deadlines upon a showing of good cause by either party based on matters arising from an emergency nature or unavailability. However, once the Agreed Case Management Plan has been approved by the Court, procrastination in completing discovery or the unavailability of counsel will not constitute good cause for a change to these deadlines. The failure to abide by these deadlines may result in sanctions by the Court, including the award of attorney’s fees, the striking of pleadings, and/or a dismissal of the action. Date:04/29/2021 Signature, address and telephone number of C ‘ounsel and Unrepresented Parties. Counsel must state FL Bar number: /s/ Daniel A. Alvarez, isi ake A, Roth Daniel A. Alvarez Jake A. Roth 7750 SW 117th Avenue, Suite 206 600 North Pine Island Road, Suite 500 Miami, FL 33183 Plantation, FL 33324 dalvarez@alvarez.legal jake.roth@csklegal.com Florida Bar No, 58842 Florida Bar No. 1025881ORDER APPROVING AGREED CASE MANAGEMENT PLAN THE COURT having reviewed the preceding Agreed Case Management Plan and finding it to be satisfactory, it is ORDERED AND ADJUDGED that the Agreed Case management Plan is hereby APPROVED AND ALL PARTIES SHALL ABIDE BY THE TERMS HEREIN. DONE AND ORDERED in Collier County, Florida on 5 “. | aH i nm. Ps Brodie. CERTIFICATE OF SERVICE Pursuant to Rule 1.080 of the Florida Rules of Civil Procedure, conformed copies have been mailed this 3 day of. Many , 2021, to the following: Copies +o Cooneel of Record